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The Honorable Dr. Ernest Moni z 

Secretary of Energy 

U.S. Department of Energy 

1000 Independence Avenue SW 

Washington, DC 20585 

Dear Secretary Moniz, 

June 12, 201 5 

I write this Jetter to urge you to postpone the rulemaking regulating nonweatherized natural gas furnaces, as set fo rth in the Federal Register notice of Proposed 

Rulemaking (NOPR). I am concerned that the rule would adversely impact low-income 

renters and homeowners. As a member of Congress, I fully support energy efficiency 

standards when they reduce monthly utility costs and carbon emissions, particularly for 

those in vulnerable communities. However, I fear that the proposed rule would do 

neither, and result in higher energy costs for low-income consumers in the long run. 

The proposed rulemaking mandates replacement of non-condensing natural gas 

furnaces with newer condensing models. Whi le more energy efficient, condensing 

models require signifi cant up-front purchase and installation costs. On average, 

condensing furnaces cost about $357 more than non-condensing models, and often 

require an additional $1,500 - $2,200 in installation costs due to retrofitting required to 

accommodate the condensing equipment. These costs can be much higher in older 

buildings and apartments where access to outside ventilation is not available. 

The high cost of installation and replacement will deter landlords from adopting 

condensing natu ral gas furnaces. Landlords will be unable to secure financing because 

lending metrics do not convert such investments into revenue for loan repayment, and 

landlords are not li kely to pay out-of-pocket. J.nstead, landlords will shift from energy 

effi cient non-condensing natu ral gas furnaces to less efficient non-natu ral gas appli ances, 

whi ch are less expensive to install but more costly to operate. Low-income tenants who 

pay their own utilities will see their heating costs double, and other tenants whose heating 

costs are paid by the landlord will see their rent increased, to cover the landlord 's 

additional heating expenses. 

Low-income homeowners will make similar choices for the same reasons. Many 

low-income homeowners cannot access consumer loans, and do not have the equity or 

cash savings to afford the signifi cant upfront costs of a condensing natural gas furnace. 

bishop.em ail @mail.house.gov • www.house.gov/bishop PRINTED ON RECYCLED PAPER 
Secretary Moniz 

6/12/15 

Page 2 

While it is true that low-income consumers would save money in the long run by 

switching to a condensing furnace, many low-income families don't have the financial 

flexibility to make decisions based on life-cycle-costs. As a result, these homeowners 

will adopt a furnace appliance that is less expensive to install, but more expensive to 

operate, resulting in heating bills that are double the cost of their non-condensing natural 

gas furnace. 

The potential harm to low-income tenants and homeowners is substan.t\a\. These 

fami lies and their landlords will avoid the necessa ry retrofitting expense and switch to 

alternative heating systems, which would be less expensive to install, but more costly and 

less energy efficient in the long run. I recognize that achieving energy efficiency is a 

national imperative among all Americans, but it is not a process that can be pursued by 

imposing disproportionate burdens on any single community, particularly those least able 

to bear the cost. 

I ask the Department to delay the proposed rulemaking until the results described 

above can be avoided. I look forward to working with you to fi nd a solution to this 

important matter. 

With warm regards, I remain 

San ord D. Bishop, Jr. 

Me ber of Congress